1 HuntingtonUniversity 

## Huntington University 2303 College Ave. Huntington, IN 46750 Nathan Hartman - 260-692-2057 nhartman@huntington.edu October 6, 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington DC 20590 Dear Sir or Madam, We, Huntington University, are writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request an exemption from the Federal Aviation Regulations (“FARs”) listed below so that We, Huntington University, may operate our small ultra-light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”). As described herein Huntington University’s UAV instructor is a certified UAS pilot in the United States and has experience in flying hobby Quad Copters for recreational purposes. Our Inventory includes one DJI Inspire 1 with a 4K camera with the intent for aerial videography/cinematography and UAS training, enhancing the academic community awareness for those individuals unfamiliar with UAS flight and abilities; following exemption and approval by the FAA. UAS specs below: Inspire 1 Aircraft

• Model: T600 • Weight (Battery Included): 2935 g • Hovering Accuracy (GPS Mode) • Vertical: 0.5 m • Horizontal: 2.5 m • Max AngularVelocity • Pitch: 300°/s • Yaw: 150°/s • Max Tilt Angle: 35° • Max Ascent Speed: 5 m/s • Max Descent Speed: 4 m/s2 HuntingtonUniversity • Max Speed: 22 m/s (ATTI mode, no wind) • Max Flight Altitude: 4500 m • Max Wind Speed Resistance: 10 m/s • Max Flight Time: Approximately 18 minutes • Motor Model: DJI 3510 • Propeller Model: DJI 1345 • Indoor Hovering: Enabled by default • Operating Temperature Range: -10° to 40° C • Diagonal Distance: 559 to 581 mm • Dimensions: 438x451x301 mm • Power Spectral Density: 9.06mW/MHz Inspire 1 Gimbal • Model: ZENMUSE X3 • Operating Current • Station: 750 mA • Motion: 900 mA • AngularVibration Range: ±0.03° • Mounting: Detachable • Controlable Range • Pitch: -90° to +30° • Pan: ±320° • Mechanical Range • Pitch: -125° to +45° • Pan: ±330° • Max Controllable Speed • Pitch: 120°/s • Pan: 180°/s Inspire 1 Camera • Name: X3 • Model: FC350 • Total Pixels: 12.76M • Effective Pixels: 12.4M • Image Max Size: 4000x3000 • Iso Range • 100-3200 (video) • 100-1600 (photo) • Electronic Shutter Speed: 8s

- 1/8000s3 HuntingtonUniversity • FOV (Field OfView): 94° • CMOS: Sony EXMOR 1/2.3” • Lens • 20mm (35mm format equivalent)f/2.8 focus at ∞ • 9 Elements in 9 groups • Anti-distortion • Still Photography Modes • Single shoot • Burst shooting: 3/5/7 frames • Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias • Time-lapse • Video Recording Modes • UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 • FHD: 1920x1080p24/25/30/48/50/60 • HD: 1280x720p24/25/30/48/50/60 • Max Bitrate OfVideo Storage: 60 Mbps • Supported File Formats • FAT32/exFAT • Photo: JPEG, DNG • Video: MP4/MOV (MPEG-4 AVC/H.264) • Supported Sd Card Types • Micro SD • Max capacity: 64 GB. Class 10 or UHS-1 rating required. • Operating Temperature Range: 0° to 40° C Remote Controller • Name: C1 • Operating Frequency • 922.7~927.7 MHz (Japan Only) • 5.725~5.825 GHz • 2.400~2.483 GHz • Transmitting Distance (OutdoorAnd Unobstructed): 2 km • EIRP: 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G • Video Output Port: USB, mini-HDMI • Power Supply: Built-in battery • Charging: DJI charger • Dual User Capability: Host-and-Slave connection • Mobile Device Holder: Tablet or Phone • Max Mobile Device Width: 170mm • Output Power: 9 W4 HuntingtonUniversity • Operating Temperature Range: -10° to 40° C • Storage Temperature Range • Less than 3 months: -20° to 45° C • More than 3 months: 22° to 28° C • Charging Temperature Range: 0-40° C • Battery: 6000 mAh LiPo 2S Charger • Model: A14-100P1A • Voltage: 26.3 V • Rated Power: 100 W Battery (Standard) • Name: Intelligent Flight Battery • Model: TB47 • Capacity: 4500 mAh • Voltage: 22.2 V • Battery Type: LiPo 6S High voltage battery • Energy: 99.9 Wh • Net Weight: 570 g • Operating Temperature Range: -10° to 40° C • Storage Temperature Range • Less than 3 months: -20° to 45° C • More than 3 months: 22° C to 28° C • Charging Temperature Range: 0° to 40° C • Max Charging Power: 180 W Vision Positioning • Velocity Range: Below 8 m/s (2 m above ground) • Altitude Range: 5-500 cm • Operating Environment: Brightly lit (lux > 15) patterned surfaces • Operating Range: 0-250 cm Huntington University is committed to safety with each flight. Huntington University exemption request would permit operation of ultra-light weight, unmanned (piloted by remote control) and comparatively inexpensive UAS in tightly controlled and limited airspace. Predetermined in areas away from general public, airports, heliports, and vehicular traffic for videography and UAS training purposes.5 HuntingtonUniversity Granting our, Huntington University, request comports with the Secretary of Transportation’s (FAAAdministrator’s) responsibilities and authority to not only integrate UAS’s into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems (UAS’s) in the national airspace system” under Section 333(c) of the Reform Act. Furtherwe, Huntington University, will conduct our operations in compliance with the protocols described herein or as otherwise established by the FAA. For the reasons stated below, We, Huntington University, respectfully request the grant of an exemption allowing us to operate ultra-light weight, remote controlled UAS’s to benefit/stimulate academic awareness on UAS flight, safety, videography, and agriculture use, which will promote economic growth and technological advancement through education and training for both individuals and the community at large. Such training will potentially replace and reduce the use of heavier manned aircraft containing combustible fuel for videography and agriculture needs, bringing benefit to overall public safety. UAS use through training at Huntington University would also decrease the potential of untrained and unlawful UAS piloting, as the education to the public would increase awareness of proper UAS safety. **I. Contact**  **Information** Huntington University, Nathan Hartman 2303 College Ave. Huntington, IN 46750 Tele: 260-692-2057 Email: **nhartman@huntington.edu II.**  **The Specific**  **Sections of** **Title 14**  **of the**  **Code of**  **Federal Regulations**  **from Which**  **Huntington University**  **Requests Exemption**  **are ...**  14 C.F.R. 21; 14 C.F.R. 45.23(b); 14 C.F.R. 91, et seq.; 14 C.F.R. 407 (a) (1); 14 CFR 409 (a) (2); and, 14 C.F.R. 417 (a) & (b). **III. The**  **Extent of**  **Relief Huntington**  **University Seeks**  **and the**  **Reason We**  **Seek Such**  **Relief** We, Huntington University, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seeking relieffrom any currently applicable FARs operating to prevent we, Huntington University, contemplated commercial cinematic, academic and otherflight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil6 HuntingtonUniversity unmanned aircraft systems into our national airspace as it is in the public’s interest to do so. Our, Huntington University, ultra-light weight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of our ultra-light weight UAS is expressly contemplated by the Reform Act. We would like to operate our light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all related UAS videography and training. The Reform Act guides the Secretary in determining the types of UAS’s that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities ofthe UAS’s; whether the UAS will be operated near airports or heavily populated areas: and, Whether the UAS will be operated by line of sight. 112 P.L. 95 §§ 333 (a). Each of these items reflect in favor of an exemption for us, Huntington University. Our UAS utilizes four counter-rotating propellers for balance, control and stability. Our UAS is equipped with GPS and auto return safety technology. Weighing less than ten pounds (far below the max. 55 pound limit); including camera and gimbal. Huntington University, considers safety as foremost with each flight. Our small unmanned aircraft is designed to hover in place via GPS and operate in less than 13 knot (15mph) wind. For safety, stability and fear offinancial loss we will not fly in winds exceeding 13 knot (15mph). Built in safety systems include a GPS mode that allows our UAS to hover in place when radio controls are released. No UAS operations near airports, hospitals nor police heliports, and do not operate near areas where general public is within fif ty to on hundred (50-100) yards depending on location, conditions and weather. We are constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach our location orwe suspect manned aircraft may approach near our location. Our UAS is capable of vertical and horizontal operations, and are flown only within our line of sight, as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last between ten (10) to fifteen (15) minutes, with an altitude under three hundred (300) feet. We, Huntington University, utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery in ten (10) to fifteen (15) minutes as tested. We do not operate our UAS at or below manufacture recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential7 HuntingtonUniversity for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. We do not believe in taking risks that may cause a crash, that could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. We have clocked numerous practice flights in remote areas as a hobbyist simulating flights for commercial use to gain familiarization with the characteristics of this specific UAS’s performance under different temperature and weather conditions. We, Huntington University, are extremely cautious when operating our UAS ultralight weight unmanned aircraft and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of our UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS’s into the national airspace system. Huntington University, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security. **IV. How**  **Huntington University**  **Request Will**  **Benefit the**  **Public As**  **A Whole:**  Aerial videography has been around for a long time through manned fixed wing aircraft and helicopters. These manned aircrafts pose a threat to the public through potential catastrophic crashes. Our, Huntington University, UAS pose no such threat since size and lack of combustible fuel alleviates any potential threat to the public. For companies seeking footage and students desiring to learn about aerial videography, manned aircraft is also cost prohibitive. Our, Huntington University, UAS reduces costs to local business and provides a safe and affordable learning environment for UAV education. Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS’s into the national airspace system, hence the passing of the Reform Act. Our, Huntington University, exemption request fur thers the public interest through academic awareness ofthe potential of UAV technology. Our ultra-light weight UAS is battery power and creates no emissions that can harm the environment. The consequences ofthe ultra-light weight UAS crashing is far less than a full size helicopter orfixed wing aircraft; which are have, contain combustible fuel and can cause devastation to the public. The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through our battery operated ultra-light weight UAS’s. Permitting us, Huntington University, to immediately fly within national air space furthers economic growth. Granting our exemption requests substantially furthers8 HuntingtonUniversity the economic impact for the local community of companies looking to use aerial footage and individuals looking to relocate for career advancement through academic awareness. Both ofwhich serve as a stimulus to the community. **V. Reasons**  **Why Huntington**  **University Exemption**  **Will Not**  **Ad versely**  **Affect Safety**  **or How**  **the Exemption**  **Will Provide**  **a Level**  **of Safety**  **At Least**  **Equal to**  **Existing Rule:**  Our, Huntington University, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting us, Huntington University, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow us to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols to both be used and taught in our academic setting. In addition we, Huntington University, submit the following as representations of the safety of our UAS.

• Our UAS weights less than 20 pounds complete with gimbal and high resolution cameras. • We only operate our UAS below 300 fee (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012). • Our UAS only operate for 10-15 minutes perflight. • We land our UAS prior to manufacturer recommended minimum battery levels. • We pilot our UAS through remote control only by line of sight. • Our UAS has GPS flight safety features whereby it hovers and then slowly lands if communication with the remote control pilot is lost. • We actively analyze flight data and other sources of information to constantly update and enhance safety protocols. • We only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas. • We conduct extensive pre-flight inspections and protocol, during which safety carries primary importance. • We always obtain all necessary permissions prior to operation. Our, Huntington University, safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness and instruction. While the safety record of such helicopters is remarkably astounding,9 HuntingtonUniversity the potential loss of life is diminished as UAS’s do not carry people on board and we only operate our UAS in specific areas away from mass populations. There is also no fuel on board a UAS and thus the potential forfire or explosions is greatly diminished. Lastly, the small size provides extreme maneuverability out of any potential danger. Accordingly, our UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels. **VI. A**  **Summary The**  **FAA Ma** **y Pub** **lish in**  **the Federal**  **Register** 14 C.F.R. 21 & 14 C.F.R. 91: Airworthiness Certificates, Manuals and the like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203 (a) (1). The size, weight and enclosed operational area of our, Huntington University, UAS permits exemption from Part 21 because our UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft form the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS’s from the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximity to area such as airports and dense populations. Our, Huntington University, current and projected UAS’s meet or exceed each of the elements. 14 C.F.R. 91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size ofthe UAS’s, this Regulation is inapplicable. An equivalent level of safety will be achieve by maintaining our, Huntington University, safety protocols and having the UAS manual in the possession ofthe remote pilot. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700, and 32827.10 HuntingtonUniversity 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our UAS utilizes electronic global positioning systems with a barometric sensor. 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by us, Huntington University. 14. C.F.R. § 45.23: Marking of the Aircraft Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. Our UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit, or pilot station on which to mark certain words or phrases. Further, two-inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, We will mark our UAS in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. § 45.29 (f) so that we the pilot, or anyone assisting as a spotterwith the UAS will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. 14 C.F.R. 91.119: Minimum Safe Altitudes 14 C.F. R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Our UAS will operate at altitude at or lower than 300 AGL; safely below the standard 400 AGL. We, Huntington University, will however operate our UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of our UAS, an equivalent or higher level of safety will be achieved. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & (b): Maintenance Inspections The above-cited regulations require, amongst other things, aircraft owners and operators to “have the aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...” These regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to our, Huntington University, UAS. However, as a safety11 HuntingtonUniversity precaution we inspect our UAS before and after each flight as well as maintaining a maintenance log. **In Summary** **, Huntington**  **University seek**  **an exemption**  **from the**  **following regulations:**  14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. § 91.7 (a); 14 C.F.R. §91.9 (b) (2); 14 C.F.R. § 91.103 (b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a) (1); 14 C.F.R. § 91.409 (a) (2); 14 C.F.R. § 91.409 (a) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) Exemption would allow us to commercially operate our, Huntington University, small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness, videography, and education. Currently, area such tasks are primarily done through larger manned aircrafts running on combustible fuel. Our UAS craft do not contain potentially explosive fuel, are smaller, lighter and more maneuverable than conventional manned videography aircraft. Granting our, Huntington University, request for exemption will reduce current risk levels and thereby enhance safety. We, Huntington University, have been informally analyzing flight information and will compile safety protocols and the implementation of a flight operations manual for videography and training usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA’s internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board our, Huntington University, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. Our, Huntington University, operation of our UAS, weighing less than 20 pounds and traveling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARSs. Accordingly We, Huntington University, respectfully request that the FAA grant our exemption request and are willing to cooperate in sharing the information to benefit the FAA, safety of manned aircraft, and the general public at large. Respectfully submitted, Nathan Hartman Huntington University - 2303 College Ave. Huntington, IN 46750